How to Update Beneficial Ownership Information

Step 1: Confirm You Still Have a Filing Obligation at All

Before worrying about updating anything, confirm your company is still a "reporting company" under FinCEN's current rule. Since the rule that took effect August 14, 2026, U.S.-formed companies are exempt from beneficial ownership information reporting entirely, so a domestic LLC or corporation has no report on file to update. This update process applies to a foreign reporting company, meaning an entity formed under a foreign country's law that's registered to do business in the United States and doesn't qualify for another exemption.

Step 2: Know What Counts as a Reportable Change

If your foreign reporting company still files, an update is required when previously reported information changes, including:

• A new individual becomes a beneficial owner, or someone who was reported no longer qualifies as one.
• A reported beneficial owner's name, address, date of birth, or identifying document changes, including a renewed passport with a new number.
• The reporting company's own legal name, trade name, or address changes.
• The company stops qualifying for an exemption it previously relied on, which can turn it into a reporting company for the first time.

A change in a company's ownership percentage that doesn't change who qualifies as a beneficial owner, or doesn't change any of their reported details, generally doesn't require an update on its own.

Step 3: File the Updated Report Within 30 Days

Once a reportable change happens, file an updated BOI report within 30 calendar days through FinCEN's BOI E-Filing System at boiefiling.fincen.gov. There's no fee to file. The update replaces the previously filed information with the current information; you don't need to explain what changed, just submit the corrected, current report.

Step 4: Correct Errors as Soon as You Find Them

If you discover that a report you already filed contained inaccurate information, whether a typo in an address or an owner who was misidentified, file a corrected report as soon as you become aware of the error rather than waiting until your next scheduled update. FinCEN's FAQs describe this as a prompt, good-faith correction process, distinct from the 30-day clock that applies to a genuine change in the underlying facts.

Step 5: Keep a Record of What You Filed and When

Keep your own copy of each report you file, along with the date and what changed, as part of your company's compliance records. If FinCEN or a bank later asks about your beneficial ownership history, having your own filing record saves time compared to reconstructing it from FinCEN's system after the fact.

Step 6: Check State-Level Obligations Separately

Beneficial ownership disclosure can also exist at the state level, separate from the federal rule. New York's LLC Transparency Act, for example, requires a foreign-formed LLC authorized to do business in New York to file a disclosure, or an attestation of exemption, with the New York Department of State, independent of whatever FinCEN currently requires. If your company operates in New York or a state that later adopts a similar law, check that state's own update and renewal process separately. See our guide on beneficial ownership reporting for how the federal and state layers currently fit together.

Step 7: Keep Checking fincen.gov/boi

Because this rule has changed substantially more than once in a short period, both the question of who has to file and the mechanics of updating a report could change again. Before relying on this guide for a specific filing decision, confirm the current rule directly on fincen.gov/boi.

Don't Confuse "No Longer Required to File" With "Should Withdraw a Past Filing"

If your company filed a BOI report before the 2025 and 2026 rule changes and is now exempt as a U.S.-formed company, FinCEN's current guidance doesn't require you to take any action to withdraw that earlier filing; the exemption simply means you have no ongoing obligation to update or refile going forward. Check FinCEN's current FAQs if you want to confirm this applies to your specific situation.

A Missed 30-Day Update Can Still Carry Penalties

For a foreign reporting company still in scope, missing the 30-day window to update a genuine change is treated similarly to other reporting failures under the Corporate Transparency Act, and penalties can apply for a willful failure to keep the report current. Treat the 30-day clock as a real deadline, not a guideline.

Build the Update Into Whatever Already Tracks Ownership Changes

If your foreign reporting company already has a process for documenting ownership changes, such as updating a cap table or membership ledger, tie the BOI update to that same process rather than relying on someone remembering to check FinCEN separately every time an owner's details change.

This Is Not Legal Advice

Whether a specific change requires an update, whether your company still qualifies for an exemption, and how a state-level law interacts with the federal rule are fact-specific questions that depend on your company's structure. Talk to a business attorney if your company is a foreign reporting company or if your exemption status has changed.